The Consumer Electronics Association , the NAB and MSTV (Association for Maximum Service Television) filed joint comments in the proceeding on the coupon program for D-to-A converter boxes that's being managed by the National Telecommunications and Information Administration. The commenters listed five principles they agreed should guide the program: 1) continued consumer access to broadcast television; 2) availability of high-quality, easy-to-use, low-cost digital converter boxes; 3) simplicity and clarity; 4) fairness and prevention of waste and abuse; and 5) industry cooperation to service the consumer.

The commenters asked NTIA to include analog sets in cable or satellite-served homes in the program and not impose a means test to determine eligibility. They also said the NTIA should adopt technical criteria somewhat stricter than ATSC Recommended Practice A/74 for converter boxes included in the program. Converter boxes covered under the program should be allowed to support added features such as electronic program guides or smart antenna interfaces. Energy-efficiency requirements should be covered under federal guidelines and not individual state requirements.

Appendix A of the MSTV and NAB comments lists the proposed functional and performance requirements. The appendix lists adjacent and taboo channel rejection thresholds, includes a table showing single echo performance +/- 50 microseconds from the main signal, and offers a more relaxed criteria if the converter is able to demonstrate reception of at least 37 of 50 field ensembles.

A diverse group of organizations, representing consumers (National Consumers League), broadcasters, manufacturers, farmers, and labor (IBEW) sent a letter to John M. R. Kneuer, acting assistant secretary of the NTIA, detailing eight principles the agency should follow in the converter box program.

These principles include implementation of "a consistent and effective consumer education strategy that reaches all consumers--especially those consumers most likely to rely on over-the-air broadcasts--where they live and work." The letter also states "converter equipment must be easy to install and use, be affordable, and exhibit excellent reception performance," and says NTIA "should follow the minimum performance requirements as agreed to and recommended by the broadcasters and manufacturers in the joint MSTV/CEA/NAB filing in this proceeding."

The letter notes that energy efficiency is an important consideration and encourages NTIA to rely on the EPA EnergyStar program for coupon eligible DTV converter boxes.

It is encouraging to see so many organizations agreeing on the how to handle this important part of the transition to digital TV and the shut down of analog TV broadcasting.

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